The report you skipped — FC-GPR after allotment, FC-TRS after a transfer, ODI Form after the remittance, APR after year-end — does not vanish. For specified delays, RBI allows reporting with Late Submission Fee instead of pushing every file straight to compounding. That is a relief valve, not a product.
We will not paste an LSF rupee formula here. The calculation follows the Master Direction / OI Directions in force for your form and delay period. Anyone selling “LSF at ₹X per month” on a CA blog is guessing. We compute from the circular that applies to your reporting date.
How this page differs
- LSF versus compounding versus a still-open contravention — three different conversations.
- No invented fee table; the AD bank applies RBI’s formula to your delay.
- Tied to ODI vs OPI and APR so the late form is the right form.
Who this is for
- Indian companies that remitted share capital abroad and never filed the ODI report
- Start-ups that allotted shares to a non-resident and missed FC-GPR
- Groups that filed APR late or never
- CFOs who were told “pay LSF and it is closed” without reading the eligibility conditions
How we work
- 01
Identify the missed reporting event
Allotment, remittance, transfer, APR, FLA — each has a form and a clock. LSF is not one challan for all of FEMA.
- 02
Test whether LSF is available
Eligibility, delay cap, and excluded contraventions are in the live RBI directions. If LSF is not available, compounding or another regularisation path is a different engagement.
- 03
Pack the AD bank file
Late form, workings for the fee, board papers, and a consistent 15CA/FEMA story. The bank remits LSF as instructed — PJRJ does not collect it.
What you receive
- Event-wise list of missed filings
- Working for LSF versus “this is compounding territory”
- Draft reporting pack for the AD bank
- Tax alignment if the same flow also needed 15CA/CB
LSF is not compounding
Compounding under FEMA is an application to RBI (or the compounding authority) to settle a contravention. LSF is a fee for delayed submission of specified reports so the report can still be taken on record without that full compounding path — when the directions say so. Using the wrong word with your board is how minutes get sloppy.
Some delays and some contraventions (for example, investment that was never eligible) do not become clean because you offer to pay a fee. We will say so before you wire money.
- Delayed reporting of an otherwise eligible ODI / FDI event → often an LSF conversation with the AD bank.
- Investment in a prohibited activity, round-tripping, or limit breach → not “just LSF.”
- FLA non-filing may have its own late-fee / reporting path — do not assume the ODI LSF grid.
- Income-tax 15CA defaults are a different statute; paying LSF does not fix a 195 short-deduction.
What we will put in writing
Date of the transaction, date of the (late) report, form name, and the circular paragraph used for the fee. If the bank’s calculator differs, the bank’s calculator — applied to your facts — is what you pay. Our memo is the classification and the document trail, not a substitute RBI receipt.
Common questions
Direct answers for searchers and answer engines
No. LSF attaches to a delayed submission. Paying a fee with no report does not create a reporting trail.
No. The formula and caps change with RBI directions and depend on delay length and amount involved. We compute on the engagement, from the text in force.
No. FEMA reporting and income-tax remittance information are parallel. See Part C vs D and the §195 chart for the tax side.